State v. Steinly, 2015 UT 15

Background

Michael Steinly was charged with multiple first‑degree felonies; charges filed December 18, 2009. He was found indigent and initially represented by county public defenders; private counsel later appeared.
Utah amended its Indigent Defense Act (IDA), effective May 8, 2012, conditioning eligibility for public defense resources on retention of publicly funded counsel (preventing privately retained counsel from also receiving public funds).
Steinly filed a motion for publicly funded expert and investigator on June 4, 2012 (after the amendments’ effective date); Salt Lake County opposed application of the amended IDA.
The district court applied the pre‑amendment IDA (because charges and indigency determination predated the amendments) and granted Steinly’s funding motion.
County sought interlocutory appeal; Utah Supreme Court reviewed de novo and reversed, holding the 2012 amendments applied to Steinly’s June 2012 motion and upholding the amendments against constitutional attack.

Issues

Issue	Steinly's Argument	County's Argument	Held
Whether 2012 IDA amendments apply to Steinly’s funding motion filed June 4, 2012	The pre‑amendment statute governs because charges, indigency determination, and appointment occurred in 2009	Amendments apply because they are procedural and/or clarify prior law and thus govern pending cases	Held: 2012 amendments apply; governing law is the law in effect when the regulated event (here, request for public defense resources) occurs
Whether a "clarifying amendment" exception makes the 2012 changes retroactive	The amendments altered substantive rights and thus pre‑amendment law should control	Amendments merely clarify/amplify existing law and should apply retroactively	Held: Court rejects a free‑standing "clarifying amendment" exception; not necessary to decide because event‑based rule controls
Whether application of the 2012 amendments violates Sixth Amendment right to counsel of choice and to defense resources	Conditioning public resources on accepting public counsel infringes choice and access to necessary resources	Legislature may condition public funding on government‑provided counsel; defendants can choose private counsel but forfeit public resources	Held: No constitutional violation; defendants may choose private counsel but have no right to public funding for that private counsel absent showing public system is inadequate
Whether the 2012 amendments violate Equal Protection / Uniform Operation (Utah)	The amendments irrationally discriminate against indigent defendants who retain private counsel	State has a rational interest in controlling and efficiently administering public defense funds via a single‑source system	Held: Statute survives rational‑basis review; upheld as rationally related to legitimate government interest

Key Cases Cited

State v. Parduhn, 283 P.3d 488 (Utah 2011) (prior construction of IDA referenced)
State v. Clark, 251 P.3d 829 (Utah 2011) (apply law in effect at time of regulated event)
Gressman v. State, 323 P.3d 998 (Utah 2013) (rejects clarifying‑amendment exception to retroactivity analysis)
Waddoups v. Noorda, 321 P.3d 1108 (Utah 2013) (confirms retroactivity principles and statutory interpretation)
Landgraf v. USI Film Prods., 511 U.S. 244 (U.S. 1994) (retroactivity: law that attaches new legal consequences to completed events is disfavored)
Britt v. North Carolina, 404 U.S. 226 (U.S. 1971) (indigent defendants entitled to basic tools of adequate defense)
Ake v. Oklahoma, 470 U.S. 68 (U.S. 1985) (state must provide access to resources necessary for an adequate defense)
Wheat v. United States, 486 U.S. 153 (U.S. 1988) (limits on right to chosen counsel for indigents)
Ross v. Moffitt, 417 U.S. 600 (U.S. 1974) (states need not duplicate privately available legal arsenal for indigents)
Gideon v. Wainwright, 372 U.S. 335 (U.S. 1963) (right to counsel for indigent criminal defendants)
Kirby v. Illinois, 406 U.S. 682 (U.S. 1972) (Sixth Amendment right to counsel attaches at initiation of adversary proceedings)